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The Comptroller has to ensure the prescribed legal requirements are followed to strike a balance between "the competing interests" of facilitating tax exchange information and safeguarding confidential taxpayers' information, wrote Chief Justice Menon on the court's behalf.

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The insurance sector made up three out of eight cases so far this year which have resulted in the commission dishing out fines.

They prompted it to release an advisory yesterday which spells out the safeguards companies must have in place when handling documents containing personal data.

The banks named were the Singapore branch of Woori Bank, UBS AG and OCBC Bank.

The Korean officials had informed Singapore's Comptroller of Income Tax of the alleged tax evasion scheme, which claimed to show the firms had been used to receive unreported income.

The Court of Appeal, which dismissed the in-camera appeal last September, in detailed judgment grounds earlier this month made clear that "the Comptroller is under no duty to hold an independent investigation or mini-trial to test the correctness of statements made by a foreign tax authority".

But this did not mean the Comptroller "can act uncritically or unthinkingly" in processing a request, said the Court comprising Chief Justice Sundaresh Menon and Judges of Appeal Tay Yong Kwang and Steven Chong.

The documents contained each client's full name, residential address, policy details and the sum assured.

The lack of additional checks was consistent with the "systemic problem" found last October, when Aviva was fined ,000 for inadvertently disclosing a policyholder's insurance documents to the wrong person.

NOT COMPTROLLER' S DUTY The Comptroller is under no duty to hold an independent investigation or mini-trial to test the correctness of statements made by a foreign tax authority.

THE COURT OF APPEAL, in detailed judgment grounds earlier this month.

They include performing test runs when printing, as well as mandating a second layer of random checks by a supervisor when putting letters in envelopes.

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